Last reviewed: February 28, 2025

This Privacy Policy describes our policies and procedures regarding the collection, use, and disclosure of your Information when you use the Service. It also tells you about your privacy rights and how the law protects You.

We use your data to provide and improve the Service. Using the Service, you agree to collect and use Information according to this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

Definitions

For this Privacy Policy:

• An account is a unique account created for you to access our service or parts of our service.

• Business, for the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal Information and determines the purposes and means of the processing of Consumers’ data or on behalf of which such Information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ Personal Information, that does business in the State of California.

• Company (referred to as either “the Company,”” “We,”” “Us,” or “Our” in this Agreement) refers to Sevilla Law, P.O. Box 280, Silver Springs, FL 34489

  For the GDPR, the Company is the Data Controller.

• For the CCPA (California Consumer Privacy Act), a consumer is a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

• Cookies are small files that a website places on your computer, mobile device, or any other device. They contain details of your browsing history on that website and are used for many different purposes.

• Country refers to: FL, United States.

• For the GDPR (General Data Protection Regulation), the data controller refers to the Company as the legal person that, alone or jointly with others, determines the purposes and means of processing Personal Data.

• Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.

• Do Not Track (DNT) is a concept promoted by U.S. regulatory authorities, particularly the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.

• Facebook Fan Page is a public profile named Sevilla Law created explicitly by the Company on the Facebook social network, accessible from https://www.facebook.com/sevillalaw.

• Personal Data is any information that relates to an identified or identifiable individual.
  For GDPR, Personal Data means any information relating to you, such as a name, an identification number, location data, an online identifier, or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity.
  For the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Under the CCPA (California Consumer Privacy Act), the sale means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

• Service refers to the Website.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used. For the GDPR, Service Providers are considered Data Processors.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website refers to Sevilla Law, accessible from https://www.inaesq.com/

• You mean the individual accessing or using the Service, the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User, as you are the individual using the Service.

Collecting and Using Your Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable Information that can be used to contact or identify You. Personally Identifiable Information may include, but is not limited to:

•  Email address

•  First name and last name

•  Phone number

•  Address, State, Province, ZIP/Postal code, City

•  Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service by or through a mobile device, we may automatically collect certain Information, including, but not limited to, the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.

We may also collect information your browser sends whenever you visit our service or access it using a mobile device.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity of our service and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track Information and improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct your browser to refuse all cookies or indicate when a cookie is being sent. However, if You do not accept Cookies, You may be unable to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse cookies, our Service may use Cookies.

• Flash Cookies. Certain Service features may use locally stored objects (or Flash Cookies) to collect and store Information about Your preferences or activity on our Service. Flash cookies are not managed using the same browser settings as those used for browser cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_.

• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a specific section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: What Are Cookies?

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to providing you with services available through the Website and enabling you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services you have asked for cannot be provided, and we only use these Cookies to provide you with those services.

• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies identify if users have accepted cookies on the Website.

• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow us to remember your choices when you use the Website, such as your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid having to re-enter your preferences every time you use the Website.

• Tracking and Performance Cookies
  Type: Persistent Cookies
  Administered by: Third-Parties
  Purpose: These Cookies are used to track Information about traffic to the Website and how users use the Website. The Information gathered via these Cookies may directly or indirectly identify you as an individual visitor. The Information collected is typically linked to a pseudonymous identifier associated with your device when accessing the Website. We may also use these cookies to test new pages, features, or functionality of the website and see how our users react to them.

For more Information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring its usage.

• To manage your account, you must register as a service user. The Personal Data You provide can give you access to different Service functionalities as a registered user.

• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.

• To contact You: We will contact you by email, telephone call, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications, regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such Information.

• To manage Your requests: To attend and manage Your requests to Us.

• To deliver targeted advertising, we may use your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and measure its effectiveness.

• For business transfers: We may use Your Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your Information for different purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and your experience.

We may share Your Personal Information in the following situations:

• With Service Providers: We may share your personal Information with Service Providers to monitor and analyze the use of our Service, advertise on third party websites to You after You visit our Service, and contact You.

• For business transfers: We may share or transfer Your Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your Information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or are under common control with Us.

• With business partners: We may share your Information with our business partners to offer certain products, services, or promotions.

• With other users: When you share personal Information or otherwise interact in public areas with other users, such Information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your Personal Information for any other purpose with Your consent.

Retention of Your Data

The Company will retain Your Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when it is used to strengthen the security or improve the functionality of Our Service or when we are legally obligated to keep it for more extended periods.

Transfer of Your Data

Your information, including personal data, is processed at the company’s operating offices and any other place where the parties involved are located. This means that this Information may be transferred to and maintained on computers outside your state, province, country, or other governmental jurisdiction where the data protection laws differ from yours.

Your consent to this Privacy Policy, followed by Your submission of such Information, represents Your agreement to that transfer.

The Company will take all necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of Your Data will occur to an organization or a country unless adequate controls exist, including the security of your data and other personal Information.

Disclosure of Your Data

Business Transactions

Your Data may be transferred if the Company is involved in a merger, acquisition, or asset sale. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may disclose Your Data if required by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other legal requirements

The Company may disclose Your Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of Your Data

The security of Your Personal Data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect Your Personal Data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Data

The Service Providers We use may have access to Your Data. These third-party vendors collect, store, use, process, and transfer Information about Your activity on Our Service through their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

•  Google Analytics

   

  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network.

   

  You can opt out of having your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information about your visit activity with Google Analytics.

   

  For more Information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Behavioral Remarketing

The Company uses remarketing services to advertise to you after you access or visit our Service. We and our third-party vendors use cookies and non-cookie technologies to help us recognize Your Device and understand how you use our Service so that we can improve our Service to reflect your interests and serve you advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process, and transfer Information about Your activity on Our Service through their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service

• Show advertisements for our products and/or services to You on third-party websites or apps

• Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of Information to serve You interest-based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA’s opt-out platform http://www.youronlinechoices.com/

• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt out of all personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See your mobile device’s Help system for more information.

We may share Information, such as hashed email addresses (if available) or other online identifiers collected on Our Service, with these third-party vendors. This allows third-party vendors to recognize and deliver your ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

•  Google Ads (AdWords)

   Google Inc provides Google Ads (AdWords) remarketing service.

   You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

   Google also recommends installing the Google Analytics Opt-out Browser Add-on—https://tools.google.com/dlpage/gaoptout—for your web browser. This Add-on allows visitors to prevent their data from being collected and used by Google Analytics.

   For more Information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

   

• Facebook

  Facebook Inc. provides a Facebook remarketing service.

  You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266.

  To opt out of Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

  Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

  For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

•  Instagram

  Their Privacy Policy can be viewed at https://help.instagram.com/519522125107875.

Usage, Performance, and Miscellaneous

We may use third-party service providers to improve our service.

•  Invisible reCAPTCHA

  We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

  The reCAPTCHA service may collect Information from You and Your Device for security purposes.

  The Information gathered by reCAPTCHA is held following the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have consented to process personal data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary to protect your vital interests or those of another natural person.

• Public interests: Processing Personal Data is related to a task carried out in the public interest or exercising official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the legitimate interests pursued by the Company.

In any case, the Company will gladly help clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Data. The right to access, update, or delete the Information We have on You. You can access, update, or request the deletion of Your Data directly within Your account settings section whenever possible. If you cannot perform these actions, please get in touch with us for assistance. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information. We hold about You corrected.

• Object to processing of Your Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation that makes you want to object to our processing of Your Personal Data on this ground. You also have the right to object where we are processing Your Personal Data for direct marketing purposes.

• Request the erasure of Your Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Data. We will provide your data in a structured, commonly used, machine-readable format to you or a third party you have chosen. Please note that this right only applies to automated Information that You initially provided consent for Us to use or where We used the Information to perform a contract with You.

• Withdraw your consent. You have the right to withdraw your consent to use your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Data. For more Information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Data collected while using the Service. As operators of the Facebook Fan Page (https://www.facebook.com/Page), the Company and the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are primarily based on the Facebook Terms of Service: https://www.facebook.com/terms.php.

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more Information about how Facebook manages Personal data or contact Facebook online or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function to operate the Facebook Fan Page and, in accordance with the GDPR, obtain anonymized statistical data about our users.

For this purpose, Facebook places a Cookie on the user’s device when they visit Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for two years, except when it is deleted before the end of this period.

Facebook receives, records, and processes the Information stored in the Cookie, especially when the user visits Facebook services, services provided by other members of the Facebook Fan Page, and services provided by other companies that use Facebook services.

For more Information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy notice section for California residents supplements the Information in Our Privacy Policy and applies solely to all visitors, users, and others who reside in California.

Categories of Personal Information Collected

We collect Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Information that we may collect or may have collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean we collected all examples of that category of Personal Information. Still, to the best of our knowledge, it reflects our good faith belief that some of that Information from the applicable category may have been collected. For example, specific categories of Personal information would only be collected if You provided such Personal Information directly to Us.

• Category A: Identifiers.

  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

  Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with different categories.

  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.

  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic Information).

  Collected: No.

• Category D: Commercial Information.

  Examples: Records and history of products or services purchased or considered.

  Collected: No.

• Category E: Biometric Information.

  Examples: Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying Information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

  Collected: No.

• Category F: Internet or other similar network activity.

  Examples: Interaction with our Service or advertisement.

  Collected: Yes.

• Category G: Geolocation data.

  Examples: Approximate physical location.

  Collected: No.

• Category H: Sensory data.

  Examples: Audio, electronic, visual, thermal, olfactory, or similar Information.

  Collected: No.

• Category I: Professional or employment-related Information.

  Examples: Current or past job history or performance evaluations.

  Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

  Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  Collected: No.

• Category K: Inferences drawn from other Personal Information.

  Examples: A profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  Collected: No.

Under CCPA, Personal Information does not include:

• Publicly available Information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA’s scope, such as:

  • Health or medical Information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

  • Personal Information covered by specific sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from You. For example, you express or provide them through our service from the forms you complete on our service and preferences.

• Indirectly from You. For example, from observing Your activity on our Service.

• Automatically from You. For example, through cookies, we or our service providers set them on your device as you navigate our service.

• From Service Providers. For example, third-party vendors can monitor and analyze our service, deliver targeted advertising to you, or use other third-party vendors that we use to provide the service to you.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.

• We aim to support and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our service.

• We will use your personal information to fulfill or meet the reason you provided the Information. For example, if you share your contact information to ask a question about our Service, we will use that personal Information to respond to your inquiry.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• This is described to you when collecting your personal Information or as otherwise outlined in the CCPA.

• For internal administrative and auditing purposes.

• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. Please refer to the “Use of Your Personal Data” section for more details on how we use this Information.

If we decide to collect additional categories of personal Information or use the Personal information we collect for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes:

•  Category A: Identifiers

•  Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

•  Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were disclosed. Still, to the best of our knowledge, it reflects our good faith belief that some of that Information from the applicable category may have been disclosed.

When we disclose Personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal Information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means a consumer’s personal information by the business to a third party for valuable consideration. We may have received some benefits for sharing personal Information, but it is not necessarily monetary.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of Personal information were sold. Still, to the best of our knowledge, it reflects our good faith belief that some of that Information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of Personal Information:

•  Category A: Identifiers

•  Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

•  Category F: Internet or other similar network activity

Share of Personal Information

We may share Your Personal Information identified in the above categories with the following categories of third parties:

•  Service Providers

•  Our affiliates

•  Our business partners

•  Third-party vendors to whom You or Your agents authorize Us to disclose Your Personal Information in connection with products or services We provide to You

  .

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers We actually know are less than 16 years of age unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age or the parent or guardian of a Consumer less than 13 years of age. Consumers who sell personal information may opt out of future sales anytime. To exercise the right to opt out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal Information, please contact us with sufficient detail to enable us to delete that Information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal Information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified of which categories of personal data are being collected and the purposes for which the personal data is being used.

• The right to request. Under CCPA, you have the right to request that we disclose Information about our collection, use, sale, disclosure for business purposes, and sharing of personal Information. Once We receive and confirm Your request, We will disclose to You:

  • The categories of personal Information We collected about You

  • The categories of sources for the personal Information We collected about You

  • Our business or commercial purpose for collecting or selling that personal Information

  • The categories of third parties with whom We share that Personal Information

  • The specific pieces of personal Information We collected about You

  • If we sell Your Personal Information or disclose Your Personal Information for a business purpose, We will reveal to You:

    • The categories of personal information categories sold

    • The categories of personal information categories disclosed

• The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us not to sell Your Personal Information. To submit an opt-out request, please get in touch with Us.

• The right to delete Personal Data. You have the right to request the deletion of Your Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Information from our records unless an exception applies. We may deny Your deletion request if retaining the Information is necessary for Us or Our Service Providers to:

  • Complete the transaction for which we collected the Personal Information, provided a good or service that You requested, and took actions reasonably anticipated within the context of our ongoing business relationship with You or otherwise performed our contract with You.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the deletion of information may likely render it impossible or seriously impair the research’s achievement if you previously provided informed consent.

  • Enable sole internal uses that align with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that Information that are compatible with the context in which You provided it.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:

  • Denying goods or services to You

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to You

  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

To exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By visiting this page on our website: www.inaesq.com/contact-us

Only You, or a person registered with the California Secretary of State You authorize to act on Your behalf, may make a verifiable request related to Your Personal Information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal Information or an authorized representative

• Describe Your Request with enough detail that will enable Us to understand, evaluate, and respond to it properly

We cannot respond to Your request or provide You with the required Information if we cannot:

• Verify Your identity or authority to make the request

• And confirm that the Personal Information relates to You

We will disclose and deliver the required Information free of charge within 45 days of receiving Your verifiable request. The period to provide the required Information may be extended once by 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12 months preceding the verifiable request’s receipt.

For data portability requests, we will select a format to provide your personal Information that is readily usable and should allow you to transmit the Information from one entity to another without hindrance.

Do Not Sell My Personal Information

You have the right to opt out of selling your personal information. Once we receive and confirm a verifiable consumer request from You, we will stop selling your personal Information. To exercise your right to opt out, please get in touch with us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal Information as defined by the CCPA law. If you wish to opt out of using Your Personal Information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt-out is specific to the browser You use. You may need to opt out of every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA’s opt-out platform http://www.youronlinechoices.com/

• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt-out will place a cookie on your computer that is unique to the browser you used to opt-out. If you change browsers or delete the cookies saved by your browser, you must opt-out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of Information about the apps You use to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

• “Limit Ad Tracking” on iOS devices

You can also change the preferences on your mobile device to stop the collection of location information.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do track your browsing activities. If you visit such websites, you can set your preferences in your web browser to inform them that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children’s Privacy

The Service may contain content appropriate for children under the age of 13. As a parent, you should know that children under the age of 13 may participate in activities involving collecting or using personal Information through the Service. We use reasonable efforts to ensure that before we collect any personal information from a child, the child’s parent receives notice of and consents to our personal information practices.

We also may limit how we collect, use, and store some of the Information of Users between 13 and 18 years old. In some cases, this means we will be unable to provide certain functionality of the Service to these Users. If we rely on consent as a legal basis for processing your Information and your country requires permission from a parent, we may require your parent’s permission before we collect and use that Information.

We may ask users to verify their date of birth before collecting personal Information. If the User is under 13, the Service will be blocked or redirected to a parental consent process.

Information Collected from Children Under the Age of 13

The Company may collect and store persistent identifiers such as cookies or IP addresses from Children without parental consent to support the internal operation of the Service.

We may collect and store other personal information about children if the Information is submitted by a child with prior parental consent or by the child’s parent or guardian.

The Company may collect and store the following types of personal Information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:

• First and/or last name

• Date of birth

• Gender

• Grade Level

• Email address

• Telephone number

• The parent’s or guardian’s name

• The parent’s or guardian’s email address

For further details on the Information we might collect, refer to this Privacy Policy's “Types of Data Collected” section. We follow our standard Privacy Policy for disclosing personal Information collected from and about children.

Parental Access

A parent who has already given the Company permission to collect and use his child’s personal information can, at any time:

• Review, correct, or delete the child’s Personal Information

• Discontinue further collection or use of the child’s Personal Information

To make such a request, You can write to Us using the contact information in this Privacy Policy.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will notify you via email and/or a prominent notice on Our Service before the change becomes effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By visiting this page on our website: https://www.inaesq.com/contact-us